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Showing contexts for: common source in Deepika A Mehta, Mumbai vs Dcit Cen Cir 23, Mumbai on 21 December, 2018Matching Fragments
26. The learned Authorised Representative strongly relvina tinnn the Deepika A. Menta decision of the learned Commissioner (Appeals) submitted that facts in assessee's case as well as the other cases relled upon by the learned Commissioner (Appeals) are same and identical. He submitted, assessment orders in case of all the assessees belong to the Harshad Mehta Group are not only identically worded but were passed on the very same date. He submitted, while making additions on account of unexplained investment in case of all assessees the Assessing Officer relied upon information obtained from common source. In this context, he drew our attention to the relevant observations of the Assessing Officer. He submitted, in case of the assessee the Assessing Officer has made the addition relying upon the observations made in the original assessment order. Drawing our attention to the facts discussed by the Tribunal in the case of Pratima H. Mehta, in ITA no.3443/Mum./2012 and ITA no.4288/Mum./2012, dated 5° September 2014, he submitted that facts are identical. He submitted, the same anomalies in valuation of shares as pointed out by the first appellate authority and the Tribunal in case of Hitesh S. Mehta and Pratima H. Mehta, also exist in case of the present assessee. Thus, he submitted, there being no difference in primary facts between the assessee's case and the cases of other assessees belonging to the same group, the decision of the appellate authorities in case of Hitesh S. Mehta and Pratima H. Mehta would be squarely applicable to the i?